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    <title>2025 (5) TMI 2131 - ITAT DELHI</title>
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    <description>ITAT Delhi upheld CIT(A)&#039;s decision favoring the assessee trust on multiple grounds. The tribunal rejected revenue&#039;s appeal regarding withdrawal of section 11 benefits, finding management fees and expenses were legitimate operational costs supported by evidence, with no discrepancies proven by AO. Corpus donation additions were deleted as no violation of section 13(1)(c) was established. Royalty payment disallowances were reversed since trademark transfer didn&#039;t constitute improper benefit to specified persons. Notional income additions for corporate guarantee charges were unsustainable as no actual expense was incurred. Depreciation disallowance was properly deleted by CIT(A) as no depreciation was claimed as fund application.</description>
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    <pubDate>Wed, 28 May 2025 00:00:00 +0530</pubDate>
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      <title>2025 (5) TMI 2131 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=771859</link>
      <description>ITAT Delhi upheld CIT(A)&#039;s decision favoring the assessee trust on multiple grounds. The tribunal rejected revenue&#039;s appeal regarding withdrawal of section 11 benefits, finding management fees and expenses were legitimate operational costs supported by evidence, with no discrepancies proven by AO. Corpus donation additions were deleted as no violation of section 13(1)(c) was established. Royalty payment disallowances were reversed since trademark transfer didn&#039;t constitute improper benefit to specified persons. Notional income additions for corporate guarantee charges were unsustainable as no actual expense was incurred. Depreciation disallowance was properly deleted by CIT(A) as no depreciation was claimed as fund application.</description>
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      <pubDate>Wed, 28 May 2025 00:00:00 +0530</pubDate>
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